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Aviation Would Benefit From a Change in Medical Double-Standards

, Medical Reform, Homepage Article 1Aviation Would Benefit From a Change in Medical Double-Standards

Aviation Would Benefit From a Change in Medical Double-Standards

March 14, 2019 By AOPA Australia
It’s not unusual to hear ‘horror’ stories about Private Pilots attending medical examinations to find that CASA has a policy – stored in the depths of a filing cabinet or...

It’s not unusual to hear ‘horror’ stories about Private Pilots attending medical examinations to find that CASA has a policy – stored in the depths of a filing cabinet or mainframe somewhere in Canberra – that justifies why they can no longer fly a VH-registered aircraft for recreation, or that a suite of tests are required to prove their ‘fitness’ to fly an aircraft.

Just a few days ago, AOPA Australia received the copy of a letter that was unceremoniously ‘spat’ out of the CASA AvMed printer, addressed to a member who recently underwent a Class 2 Medical. According to that pilot, he had no medical complaints or issues to declare but he has been denied that medical by the organisation until he is able to prove that his BMI (which came in 0.1 points over the threshold) is not causing him Sleep Apnoea, for which he has no reported or observed history.

This AOPA Australia member will have to visit his doctor for a ‘Raised BMI Assessment’ where it will be determined whether a follow up sleep test will need to be performed for submission to CASA. Irrespective, a blood-glucose test is now mandatory for this pilot and, if the assessment finds that he has had (either) an ‘Aircraft or Motor Vehicle Accident’ or has a ‘Neck Circumference greater than 42cm’ (among a smorgasbord other items), the sleep test becomes mandatory.

It turns out that he happens to have a neck circumference of just higher than the range required. So he is required to book in to the sleep clinic to have a night away with bleeping monitors and tubes attached to his face, and his (allegedly oversized) neck.


The standards relating to flying a ‘VH-registered’ aircraft recreationally in Australia are much higher than those required for RAAus pilots flying an RAAus registered aircraft. In the case of RAAus, CASA allows pilots to fly after self-declaring their medical status, according to the medical rules that apply to a car license.

Unfortunately, for this AOPA member and many like him, the same rules do not apply simply because they find themselves flying the same aircraft in a system that reeks of unfairness and inequality. It’s broken, unfair and remains one of the reasons the industry is uncompetitive and costly; holding us back from sustained growth during a period where Australia should be taking advantage of a booming aviation economy – and the need to train more quality pilots to satisfy worldwide demand.

By way of illustration, let’s assume our AOPA Australia member owns and operates a ‘Sling 2’ type aircraft. It’s a two-seater with a MTOW of 700kg and cruise speed of around 100kts. Under the GA system, he is effectively grounded because he doesn’t yet meet the medical standard prescribed by CASA to fly his own aircraft. As it stands, CASA deems him an unacceptable risk to himself and public safety and requires him to jump through the necessary medical ‘hoops’ to prove to them that he is safe to fly an aircraft.

But if he chooses to pay to register his aircraft with the RAAus company and pays his membership fee to them, CASA will allow him to fly his aircraft (with a passenger to an MTOW of 600kg). All he needs to do is submit a form to the company declaring that he thinks that he is able to meet the standard to fly (which he obviously does). He doesn’t even need a doctor-issued certificate declaring that he is fit to drive a car (and hence an aircraft), because he doesn’t suffer from epilepsy, diabetes, a heart condition or a mental illness, and he is not over 75 years old (the requirements for a doctor’s certificate confirming the car license standard). He is deemed to pose no increased risk to himself, his passengers or the safety of the public even though he is the same person, with the same medical status as when he visited the doctor to obtain a Class 2 medical.

We find our regulator allowing the operation of two separate medical standards in the recreational aviation space, instead of allowing all ‘recreational pilots’ to fly under the standard as a self-declaration. This is the same standard that CASA themselves admits is sufficiently safe.


With the ‘stroke of a pen’, the Director of Aviation Safety at CASA can introduce an amendment to CASR 67.180 or issue a new CAO to allow a qualified pilot that holds a current private driver’s license to operate an aircraft up to 600kg MTOW (or more if RAAus gets their anticipated increase), with up to one passenger and outside controlled airspace, after declaring that he has the same standard as required to drive a car. This would align the recreational aviation sector internally – and bring the industry more in line with the medical standards required by private drivers on our roads.

While CASA has admitted that aviation safety is not compromised by allowing recreational pilots to self-declare medical fitness, there is a nonchalance being exhibited by both CASA and the legislature in making this simple and important change. We need to band together and demand that the lunacy stops – and that CASA changes the law to re-inject a sense of logic, pragmatism and confidence into recreational aviation.

Aviation in Australia will be the ultimate winner.

Are you a member of the Aircraft Owners and Pilots Association of Australia?  Join today and stand with us as we push for pilot medical reform:


Mackey Kandarajah

AOPA Pilot Editor at Large Dave Hirschman joined AOPA in 2008. He has an airline transport pilot certificate and instrument and multiengine flight instructor certificates. Dave flies vintage, historical, and Experimental airplanes and specializes in tailwheel and aerobatic instruction.

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